FILED: NEW YORK COUNTY CLERK 10/04/2013
NYSCEF DOC. NO. 2
INDEX NO. 653440/2013 RECEIVED NYSCEF: 10/04/2013
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK _______________________________________________ Korea Consulate General New York, Plaintiff, -against-
Index No.: COMPLAINT
ISEA Communication Corp. and Andrew Choi,
Plaintiff Korea Consulate General New York for its complaint against the above-named defendants, state upon knowledge, except where indicated otherwise, as follows: THE PARTIES
1. At all relevant times, Plaintiff Korea Consulate General New York was and still is an agency of Korean Culture and Information Service whose registered office located at 335 East 45th Street New York, NY 10017.
2. At all relevant times, defendant ISEA Communication Corp. was and still is an registered New York State corporation whose principal place of business is 38 W. 32 nd St. Suite 403, New York, NY 10001. 3. At all relevant times, defendant Andrew Choi was and still is a president of ISEA Communication Corp. whose principal place of business is 38 W. 32nd St. Suite 403, New York, NY 10001. JURISDICTION AND VENUE
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4. The Court has jurisdiction based on the basis of the defendant by virtue of the CPLR § 301. 5. Venue in the County of New York is proper because it is the county of the defendants’ business. COMMON ALLEGATION 6. In May 7th, 2012, defendants and plaintiff executed a mutual Agreement, whereas plaintiff agreed to support film production and distribution of TV program services from the
7. On May 15, 2012, plaintiff made an initial payment of Fifty Thousand Dollars ($50,000.00), which is fifty percent (50%) of the production cost.
8. As per the Agreement, the defendants guaranteed that the Show will be aired by December 31, 2012.
9. On November 27, 2012, defendant sent a letter to the plaintiff, which assured its voluntary termination of the Contract and full return of Fifty Thousand Dollars ($50,000.00) by 6th or 7th of December, 2012.
10. On March 7, 2013, defendant sent a second notice to the plaintiff, which agreed to return Fifty Thousand Dollars ($50,000.00) by end of March, 2013. CLAIMS FOR RELIEF Count One – Breach of Contract 11. Paragraphs 1 through 12 are incorporated by reference.
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